been accepted without gainsaying or opposition from any temporal court, that it had been confirmed by the Book of Common Prayer in the service for the visitation of the sick, and, thus, sanctioned by the Act of Uniformity. Phillpotts was supported by Edward Lowth Badeley who wrote a pamphlet on the question of priest–penitent privilege. From the bishop's reply to Lord Westbury's answer to his letter, it is apparent that Lord Westbury had expressed the opinion that the 113th canon of 1603 simply meant that the "clergyman must not ex mero motu and voluntarily and without legal obligation reveal what is communicated to him in confession". He appears, also, to have expressed an opinion that the public was not at the time in a temper to bear any alteration of the rule compelling the disclosure of such evidence. Sentence Constance Kent was sentenced to death, but this was commuted to life in prison owing to her youth at the time and her confession. She served twenty years in a number of gaols, including Millbank Prison, and was released in 1885, at the age of 41. During her time in prison, Constance may have produced mosaics for a number of churches, including work for the crypt of St. Paul's cathedral. Noeline Kyle, in her book A Greater Guilt, discusses the work Constance was engaged in while incarcerated, including cooking, cleaning and laundry work, and what Kyle describes in light of a lack of evidence of Kent's making of any mosaics and the fact that "none of the true crime writers on this topic ... say where this information is sourced from" as the myth of the mosaics. Later life Constance emigrated to Australia early in 1886 and joined her brother William in Tasmania, where he worked as a government adviser on fisheries. She changed her name to Ruth Emilie Kaye and trained as a nurse at The Alfred Hospital in Prahran, Melbourne, Victoria, before being appointed sister-in-charge of the Female Lazaret at the Coast Hospital, Little Bay, in Sydney, New South Wales. From 1898 to 1909, she worked at the Parramatta Industrial School for Girls. She lived in the New South Wales town of Mittagong for a year, and was then made matron of the Pierce Memorial Nurses' Home at East Maitland, serving there from 1911 until she retired in 1932. Death Constance Kent died on 10 April 1944, aged 100,